Drug testing is a vital component of workplace safety, particularly in industries regulated by the Department of Transportation (DOT). This guide will serve as an overview of the DOT Drug Testing program and will provide valuable insights for both employers and employees.

Agencies That Fall Under DOT

• Federal Motor Carrier Safety Administration (FMCSA): Regulates commercial motor vehicles
• Federal Aviation Administration (FAA): Oversees aviation safety
• Federal Railroad Administration (FRA): Manages railroad safety
• Federal Transit Administration (FTA): Supervises public transportation systems
• Pipeline and Hazardous Materials Safety Administration (PHMSA): Regulates pipelines and hazardous materials transportation
• United States Coast Guard (USCG): Ensures maritime safety

Below are some of the jobs that are subject to DOT drug testing. However, this is not an exhaustive list:

• Commercial truck and bus drivers
• Pilots, flight attendants, and aircraft maintenance personnel
• Train engineers and conductors
• Ship captains and crew members
• Pipeline operators
• Transit vehicle operators

When Is DOT Drug Testing Needed?

DOT drug testing is mandated in these 6 situations:

• Pre-employment: Before an individual begins safety-sensitive duties.
• Random: Unannounced tests conducted throughout the year. Companies will normally do 10% of the staff per month, on a “random” basis.
• Post-accident: Following certain types of accidents or incidents. Anytime there is damage to equipment or there is harm done to a person, a “post-accident” specimen will likely be requested.
• Reasonable suspicion: When a supervisor observes signs of potential drug use.
• Return-to-duty: After an employee violates their company’s drug and alcohol policy, a series of “return-to-duty” tests must be performed before they can be reinstated and allowed to come back to work.
• Follow-up: Once somebody has returned to duty after a violation, a series of unannounced tests will be performed to ensure the employee is staying drug-free.

What Drugs Does DOT Testing Look For?

There are a lot of drugs/substances out there that will get you high. However, DOT drug testing looks for these 5 specific drugs for current employees and new applicants:

• Marijuana: (THC, Weed, Marijuana, Pot, Ganja)
• Cocaine: (Coke, Snow, Blow)
• Amphetamines: (Crank, Ice, Speed, Meth, Ecstacy); (includes methamphetamine and MDMA)
• Opioids: (Dope, Smack, Lean, Brown Sugar, China White); (includes codeine, morphine, heroin, hydrocodone, hydromorphone, oxycodone, and oxymorphone)
• Phencyclidine(PCP): Angel Dust, Sherm

What Are The Cutoff Levels for DOT Drug Testing

DOT drug testing involves two stages once the specimen gets to the laboratory, an initial screen and a confirmation.

During the “initial screening”, all specimens are run through a chemistry analyzer which will flag if any specimen is at or above the initial screening concentrations set by DOT.

During “confirmation”, any specimens that flagged during the initial screening, will get run a second time in order to validate the first run.

For Marijuana, Cocaine and Amphetamines, the DOT uses a lower concentration as the threshold to confirm a positive, making it a more sensitive test. However, for Opiates and Phencyclidine (PCP), the cutoff concentration does not change between the initial screen and the confirmation run.

The cutoff levels for each drug are as follows:

Marijuana

• Initial: 50 ng/ml
• Confirmation: 15 ng/ml

Cocaine

• Initial: 150 ng/ml
• Confirmation: 100 ng/ml

Amphetamines

• Initial: 500 ng/ml
• Confirmation: 250 ng/ml

Opioids

• Initial: 2000 ng/mL (except 6-Acetylmorphine: 10 ng/mL)
• Confirmation: 2000 ng/mL (except 6-Acetylmorphine: 10 ng/mL)

Phencyclidine (PCP)

• Initial: 25 ng/ml
• Confirmation: 25 ng/ml

How Long Do Drugs Stay In Your System?

This is the golden question for many people. However, the answer will vary since each individual drug metabolizes differently.

Detection times will depend on the type of drug, frequency of use, body composition, individual metabolism and type of specimen used for testing.

Despite this variability, we can estimate a rough idea of detection windows for each drug. Since urine is the most commonly used specimen type for DOT testing, we will show those detection windows below:

• Marijuana: 1-3 days for casual users; 5-10 days for daily users; up to 30 days with chronic use.
• Cocaine: 1-3 days
• Amphetamines: 2-4 days
• Opioids: 1-3 days
• Phencyclidine (PCP): 2-7 days for acute use; up to 30 days in chronic users.

Most of the drugs on this list are “water soluble“, so they will generally clear from the system in about a week max.

On the other hand, marijuana is “fat soluble“, meaning that the drug is stored in fat cells instead of clearing the body quickly. This increases the window of detection for marijuana, especially with obese people since they have more fat stores to utilize. People with higher fat content stand a greater chance of testing positive for a longer period of time than a person with less fat content, with all else being equal.

How Long Does It Take for DOT Results To Come Back

The timeframe for receiving DOT drug test results depends on the outcome of the test.

-If the results are negative they should be available within 24-48 hours.

-If the results are positive, it may take up to 3-5 business days due to additional time required for confirmation testing and MRO review.

Consequences of a Positive DOT Drug Test

When a DOT employee tests positive and they aren’t able to give the MRO a valid medical reason during their interview, several steps are taken:

-The employee is immediately removed from safety-sensitive duties.

-They must complete the return-to-duty process, which includes:

• Evaluation by a Substance Abuse Professional (SAP)
• Completion of any recommended treatment or education programs
• Passing a return-to-duty drug test

-The employee will undergo follow-up testing for a minimum of 12 months after returning to safety-sensitive duty. This can be extended to an additional 48 months if the employer chooses. During the first 12 months, employees will be subject to a minimum of 6 unannounced follow-up tests.

When Is Direct Observation Required For DOT Collection

Direct observation is not standard practice for DOT drug testing. However, it is required in specific situations like:

• Return-to-duty tests
• Follow-up tests
• When tampering is suspected during the collection process
• When a previous test was reported as invalid, substituted, or adulterated

In these cases, a same-gender observer will watch the urine stream leave the body and enter the collection container. This helps reduce the chances of the urine being substituted with fake urine or adulterated with chemicals to alter the results.

What If Medications Cause A Positive Result?

If a prescribed medication causes a positive test result on a DOT test, the Medical Review Officer (MRO) will contact the employee to inquire if there is a legitimate medical reason that would cause a positive result.

If there is a medical reason, the MRO will request a copy of any prescriptions that relate to this medical reason. The MRO will verify the information with the prescribing physician and if it is valid and explains the positive result, the test is reported as negative.

If there is no adequate medical reason given, the MRO will deem the result as positive.

Causes of False Positive Tests

While rare, false positive results can occur due to:

• Certain foods (e.g., poppy seeds for opioids)
• Over-the-counter medications (e.g.,pain medications, antibiotics, cold medicines)
• Laboratory errors

Confirmation testing and the MRO review process help to minimize the risk of false positives.

Regulations Covering DOT Drug Testing

• DOT: 49 CFR, Part 40
• FMCSA: 49 CFR, Part 382
• FAA: 14 CFR, Part 120
• FRA: 49 CFR, Part 219
• FTA: 49 CFR, Part 655
• PHMSA: 49 CFR, Part 199
• USCG: 46 CFR, Parts 4, 5, and 16

Exemptions from DOT Drug Testing

There are very few exemptions from DOT drug testing. However, some specific situations may exempt certain individuals:

• Employees who perform safety-sensitive duties so rarely that they’re unlikely to be selected for random testing
• Some emergency response personnel during declared emergencies
• Certain railroad employees in non-safety-sensitive positions

It’s crucial to note that exemptions are rare and specific to each DOT agency’s regulations. These regulations are subject to change at any time. Additionally, each agency will let you know if you are exempt or not during the hiring process.

Detecting Specimen Tampering

Tampering of urine specimens can be detected by several methods:

• Temperature checks: Collectors will check the temperature of urine specimens within 4 minutes of receiving the specimen. Using the temperature sensing strip attached to the cup, the collector will read the strip and the temperature must be between 32-38 Celsius to be considered valid. If the temperature is outside this range, it is a sign that the urine may have been substituted with another other liquid. In this situation, a new specimen must be collected.
• Visual inspection: Collectors will check for unusual color, odor, or debris. Things like blue dye, excessive foaming and the smell of bleach can signal that the specimen has been substituted and/or adulterated.
• Validity testing: Laboratories will test the creatinine concentration and specific gravity to assess potential dilution of the specimen. The pH and testing for oxidizing adulterants will also be performed to double check for any tampering that the collector could not assess via non-laboratory means.

If tampering is suspected, a second attempt will be collected under direct observation.

Consequences of Refusing DOT Drug Testing

Refusing a DOT drug test is considered equivalent to a positive test result. Refusal includes:

• Failing to appear for a test within a reasonable time.
• Leaving the testing site before the process is complete.
• Failing to provide a sufficient urine specimen without valid medical explanation.
• Failing to cooperate with any part of the testing process.
• Refusing to allow direct observation when required.
• Possessing or wearing a prosthetic or other device used to interfere with the collection process. A common example of this would be a fake penis device like the “Whizzinator”.

Consequences of refusing a DOT drug test are the same as receiving a positive result:

• Immediate removal from safety-sensitive duties.
• Referral to a Substance Abuse Professional (SAP).
• Completion of the return-to-duty process before resuming safety-sensitive functions.

Insufficient Urine Specimen Procedures

If an employee is unable to give the full 45 ml of urine that is required, the following steps will be taken:

• They are given up to 40 ounces of fluid over 3 hours so that they can hydrate. It is not mandatory to drink this fluid.
• The employee must remain at the collection site during this period.
• If still unable to provide a sufficient specimen, the test is terminated.
• The employer is notified of the “shy bladder” situation.
• The employee must obtain an evaluation from a physician to determine if there’s a medical explanation.
• If no medical explanation is found, it’s considered a refusal to test.

If a medical explanation is identified by the physician, the test is cancelled. The physician or MRO will then order a blood test to see if there is evidence of drug use:

• If the blood test is passed, the MRO will report the result as a negative to the employer.
• If the blood test is failed, the MRO will report the result to the employer as a cancelled test with written notations that signs and symptoms of drug use exist. Because this is a cancelled test, it does not serve the purposes of a negative test. Consequently, the employer is not authorized to allow the employee to begin or resume performing safety-sensitive functions, since a negative test is needed for that purpose.

Differences Between DOT and Non-DOT Drug Testing

DOT testing is only required for industries and jobs that fall under the DOT. Non-DOT testing is for those jobs that do not fall under DOT.

There are some key differences between DOT and non-DOT drug testing. This includes:

Regulated substances: DOT only tests for a specific panel of 5 drugs. Whereas, non-DOT testing can test for those 5 drugs, but also has the flexibility to test for whatever additional substances that they see fit, like Fentanyl or Spice for example.

Collection procedures: DOT tests follow strict protocols outlined in 49 CFR Part 40. With non-DOT collections, the lab normally determines the collection protocol, whether it be Quest, Labcorp, etc.

Consequences: DOT violations have specific, mandated consequences and return-to-duty processes. Consequences for non-DOT violations can vary and are determined by each individual company.

Random testing rates: DOT agencies set minimum annual testing rates for random collections. Companies that do non-DOT testing are free to choose their own annual testing rates.

DOT Drug Testing-Keeping A Safe Workplace

The DOT Drug Testing program promotes a safe work environment by testing thousands of workers in the transportation industry every year. As regulations change, it’s essential to stay informed about the latest updates and procedures.

References

1.Robert F. Forman, P., & Paul D. Nagy, M. L. (2006). Substance Abuse: Clinical Issues in Intensive Outpatient Treatment. Retrieved from National Library Of Medicine: https://www.ncbi.nlm.nih.gov/books/NBK64092/

2.Transportation, U. D. (2024, October 3). CFR 49, PART 40—PROCEDURES FOR TRANSPORTATION WORKPLACE DRUG & ALCOHOL TESTING PROGRAMS. Retrieved from Code of Federal Regulations: https://www.ecfr.gov/current/title-49/subtitle-A/part-40